EPA Issues Periodic Monitoring Guidance

On September 15, 1998, the EPA has released its Periodic Monitoring Guidance. This Guidance is intended to be used by Permitting Authorities and EPA Regional Offices in the development of Title V monitoring requirements.

Periodic Monitoring data is basis upon which a Title V Responsible Officials is to personally certify to a source's annual compliance status. This has become an issue of increasing importance given EPA's shift in enforcement focus away from the source and towards the Responsible Official as an individual.

In the Guidance:
EPA reaffirmed its position that:

Responsibility for Compliance Rest Upon the Source
Compliance obligation is continuous, and
Under all anticipated operating conditions.

EPA states that the purpose of Periodic Monitoring is to provide a basis for a source to certify its compliance status.

must yield reliable data
from the relevant (averaging) time period
that are representative of a sources compliance status
with the applicable requirement
over its anticipated operating range.

Key Provisions Require that::

Data must be reliable
Acceptable Periodic Monitoring should consider all relevant factors including:

Margin of Compliance
Source Variability
Add-on Controls
Available Data
Technical and Economic Considerations

Parametric Data can be used as an enforceable limit

Should specify a range
Document site-specific developed relationships
Periodically verify the continuing validity
Use periodic stack tests to verify direct compliance

Information must be Enforceable as a Practical Matter - elements include

Frequency of Monitoring
Procedures Used to Check Data Validity
Data Averaging Period
Minimum Data Availability
Prompt Reports of Deviations and Summary Reports

Rational for selection of monitoring method must be clear and documented, and made readily available to the public.
EPA states that this guidance in No-Way affects the use of periodic monitoring data under the EPA's Credible Evidence Rule. (The US Court of Appeals dismissed industry challenges to the Rule on August 14, 1998)